Topics

How the Corporate Transparency Act Shakes Up AML: Beneficial Ownership Updates and More FinCEN Unveils New Global Investigations Division to Target Foreign Money Laundering Threats FinCEN Announces First-Ever Enforcement Action Against Bitcoin Trader for Violations of BSA

Form 3520-A

Form 5471

Form 5472

Form 8938

What’s Next for International Reporting Post-Farhy?Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

Fourth Amendment

Carpenter May Reveal a Recipe for Defense in High-Tech Criminal and Regulatory Cases

Fraud referrals

IRS Launches Online Tool to Simplify Reporting of Tax Fraud and Scams

General Tax Controversy News & Updates

IRS Launches Online Portal for Kwong Refund Claims IRS Targeting Charitable Deductions: Old Dog, Old Tricks Rhetoric Aside, Audits of Tax-Exempt Organizations Skyrocketed in FY25

Geographic Targeting Orders (GTOs)

FinCEN Remains Mum on Details Regarding New Geographic Targeting Orders FinCEN Quietly Extends Real Estate Geographic Targeting Orders for Another Six Months FinCEN Warns U.S. Financial Institutions of Venezuelan Money Laundering Threat

Health care fraud

Fox Rothschild’s Inaugural White-Collar Symposium, Thursday, November 3 Join Us for Fox Rothschild’s Inaugural White-Collar Symposium on November 3 US Launches Nationwide Coordinated Law Enforcement Action to Combat Health Care-Related COVID-19 Fraud

Identity Theft

Identity Theft Earns Third Spot on IRS “Dirty Dozen” for 2018 Despite Recent Improvements Don't Get Caught in "Phishing Season"

Immigration

Justice Department Plans to Eliminate Tax Division by End of Summer Employers Beware: ICE Is Ramping Up I-9 Audits to Record Levels

Initial Coin Offerings

IRS-Criminal Investigation Ramps Up Scrutiny of Cryptocurrency Transactions SEC’s Office of Compliance Inspections Releases Its 2018 Examination Priorities SEC’s Cyber Unit Shutters Another Alleged Initial Coin Offering Scam As Federal Cryptocurrency Fraud Crackdown Continues

Internal Investigations

Fox Rothschild Attorneys to Present at PACDL's Annual White Collar Conference

Internal Revenue Code

Taxpayer Assistance and Service Act Title X: Miscellaneous Provisions Taxpayer Assistance and Service Act Title IX: Small Business Taxpayer Assistance and Service Act Title VII: Whistleblowers

Internal Revenue Service (IRS)

Horse Breeding and Training Expense Deductions? Tax Court Says Neigh Taxpayer Assistance and Service Act Title X: Miscellaneous Provisions Taxpayer Assistance and Service Act Title IX: Small Business

IRS "Dirty Dozen"

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales March 22 ERC Voluntary Disclosure Deadline Rapidly Approaching IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program

IRS Advisory Council

Congress Eyes Significant Cut to IRS Budget

IRS Appeals

Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals IRS Unveils More Leadership Changes as Tax Filing Season Opens Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

IRS Audits

Group of U.S. Senators Sound Alarm About State of Federal Tax Enforcement IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

IRS Budget

Group of U.S. Senators Sound Alarm About State of Federal Tax Enforcement Group of U.S. Senators Question Sharp Drop in IRS Investigations of Abusive Tax Schemes Partial Government Shutdown Ends With Funding Deal That Will Slash IRS Budget

IRS Chief Counsel

The Taxpayer Assistance and Service Act: Title III: Judicial Review IRS Commissioner’s Office Vacant Once Again IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement

IRS Collection Division

Auditor Releases "Snapshot" of IRS Workforce Revealing Devastating Extent of Initial Job Cuts IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

IRS Criminal Investigation (CI) Division

Group of U.S. Senators Sound Alarm About State of Federal Tax Enforcement Group of U.S. Senators Question Sharp Drop in IRS Investigations of Abusive Tax Schemes IRS Unveils More Leadership Changes as Tax Filing Season Opens

IRS Domestic Voluntary Disclosure Program

New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program The New IRS Voluntary Disclosure Regime: Worth the Price of Admission?

IRS Examination Division

Group of U.S. Senators Sound Alarm About State of Federal Tax Enforcement IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful Threat to Harvard’s Tax Status Reaches All Nonprofits - A Bloomberg Daily Tax Report Column

IRS Large Business and International (LB&I) Division

IRS Makes Top Leadership Moves While Federal Government Remains Shuttered IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

IRS Offshore Voluntary Disclosure Program (OVDP)

U.S. Supreme Court Rules Against Government in FBAR Penalty Case The New IRS Voluntary Disclosure Regime: Worth the Price of Admission?IRS Unveils Post-OVDP Voluntary Disclosure Procedures

IRS Private Collection Program

Trends in IRS Compliance Activities Through Fiscal Year 2016 IRS Warns Consumers of New Phone Scam Just as Private Collectors Get to Work New Details Emerge About IRS Private Debt Collection Program, as Fraudsters Continue to Impersonate IRS Collectors

IRS Taxpayer Advocate Service (TAS)

Taxpayer Assistance and Service Act Title IV: Office of the Taxpayer Advocate The Taxpayer Assistance and Service Act: Title III: Judicial Review Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

J5

Joint Chiefs of Global Tax Enforcement Mark One Year Anniversary of J5

John Doe Summons

Coinbase Notifies 13,000 of Its Customers of Upcoming Data Release to Internal Revenue Service Coinbase Ordered to Turn Over Bitcoin Trading Records of Over 14,000 Customers to Internal Revenue Service Members of Congress Question IRS’s Digital Currency Strategy Including “John Doe” Summons to Coinbase

Joint Chiefs of Global Tax Enforcement

Joint Chiefs of Global Tax Enforcement Mark One Year Anniversary of J5

Legislation

Taxpayer Assistance and Service Act Title X: Miscellaneous Provisions Taxpayer Assistance and Service Act Title IX: Small Business Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals

Malta pension arrangements

Internal Revenue Service Unveils “Dirty Dozen” Tax Scams for 2022

Micro-captive insurance

Internal Revenue Service Unveils “Dirty Dozen” Tax Scams for 2022 IRS Steps Up Scrutiny of Micro-Captive Insurance Transactions

Monetized installment sales

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales Internal Revenue Service Unveils “Dirty Dozen” Tax Scams for 2022

Money Laundering

Fox Rothschild’s Inaugural White-Collar Symposium, Thursday, November 3 Join Us for Fox Rothschild’s Inaugural White-Collar Symposium on November 3 FinCEN Unveils New Global Investigations Division to Target Foreign Money Laundering Threats

Non-Profit Organizations

Threat to Harvard’s Tax Status Reaches All Nonprofits - A Bloomberg Daily Tax Report Column Increase in IRS Funding Leading to More Audits of Public Charities May 15 Tax Deadline and ‘Start of the Year’ Review – Part I

Obstruction of Justice

IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions

Office of the Comproller of the Currency (OCC)

FinCEN and OCC Impose $7 Million Penalty on California Bank for “Egregious” Anti-Money Laundering Violations

Panama Papers

Fox Rothschild Attorneys to Speak at Federal Bar Association's 2019 Tax Law Conference More Data Added to Paradise Papers Offshore Leaks Database On Eve of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action to Mitigate Potential for Criminal Prosecution

Paradise Papers

More Data Added to Paradise Papers Offshore Leaks Database On Eve of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action to Mitigate Potential for Criminal Prosecution

Passport Revocation

National Taxpayer Advocate Boldly Countermands IRS Passport Revocation Efforts Tax Delinquents Beware: Your Passport Is Now Officially at Risk IRS Delays Start Date for Program to Revoke Passports for Tax Delinquents

Paycheck Protection Program (PPP)

False Claims Act Fallout from Pandemic Aid: What You Need to Know - A Fox Rothschild Webinar An Appealing Conversation: Insights From a Former Court of Appeals Judge Fox Rothschild’s Inaugural White-Collar Symposium, Thursday, November 3

Penalties

Horse Breeding and Training Expense Deductions? Tax Court Says Neigh Taxpayer Assistance and Service Act Title IX: Small Business Court Ruling Creates Refund Opportunity for Pandemic-Era IRS Interest and Penalties

People First Initiative

Resources Regarding "People First Initiative" Available on IRS Website

Public corruption

Fox Rothschild Defense Team Wins Full Acquittal in High-Profile Political Corruption Trial

Qui tam

Protecting Your Organization Against Paycheck Protection Program Qui Tam Actions

Reasonable Cause

IRS Cracks Down on Charitable Contributions of Cryptocurrency Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized

Refunds

The Taxpayer Assistance and Service Act: Title III: Judicial Review Court Ruling Creates Refund Opportunity for Pandemic-Era IRS Interest and Penalties With the Tariffs Struck Down, Now the Refund Fight Begins

Sales Suppression Software

Garden State “Zapper” Users Beware: New Jersey Announces Crackdown on Revenue Suppression Programs Look Out, Tax Zapper Users: Feds Join State-Level Crackdown Minnesota Joins Widening Crackdown on “Zappers” With Announcement of State’s First Criminal Convictions for Using Sales Suppression Devices

Securities Fraud

It’s All in the Timing: Insider Trading Investigations and National Emergencies No Easy Out: Federal Judge Says Selling Digital Tokens May Violate Federal Securities Laws SEC Widens Investigation of Cryptocurrency Companies

Sentencing

As Tax Day Approaches, Justice Department and IRS Turn Up Heat on Potential Tax Cheats Lessons from DOJ Prosecution of Tony Hu for Sales Tax Fraud

Small Business Administration

PPP Borrowers Face Risks in Completing SBA Form 3509

Small Business/Self-Employed

State and Local Taxes

Georgia Residents Eligible for $3,000 Tax Exemption for Each 'Unborn' Child Partnerships and S Corporations Exempted From Limits on State and Local Tax Deduction Pennsylvania Extends Personal Income Tax Return Filing Deadline to July 15, 2020

Streamlined Filing Compliance Procedures

Internal Revenue Service Reminds Taxpayers to Report Offshore Bank Accounts on FBAR Form DOJ Announces Final Resolutions Under Its Groundbreaking Swiss Bank Program As Program Enters "Legacy" Phase IRS Adds Nearly 50 New Names to OVDP Facilitator List, Effective November 15

Tariffs

With the Tariffs Struck Down, Now the Refund Fight Begins

Tax Amnesty

Internal Revenue Service Reminds Taxpayers to Report Offshore Bank Accounts on FBAR Form New Jersey Announces Possibility of Tax Amnesty Pennsylvania to Begin Issuing Penalty Assessments to Taxpayers Who Ignored 2017 Amnesty Program

Tax Controversy Litigation

Horse Breeding and Training Expense Deductions? Tax Court Says Neigh The Taxpayer Assistance and Service Act: Title III: Judicial Review The Taxpayer Assistance and Service Act: Title II: American Citizens Abroad

Tax Cuts and Jobs Act

Partnerships and S Corporations Exempted From Limits on State and Local Tax Deduction Internal Revenue Service's LB&I Division Announces Compliance Campaign Focused on TCJA Internal Revenue Service Announces It Will Waive 2018 Estimated Tax Penalties for Many Taxpayers

Tax Evasion

Trump and Congress Nullify IRS Reporting Rule for Digital Assets IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017 IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program

Tax Exempt Organizations

Threat to Harvard’s Tax Status Reaches All Nonprofits - A Bloomberg Daily Tax Report Column May 15 Tax Deadline and ‘Start of the Year’ Review – Part II May 15 Tax Deadline and ‘Start of the Year’ Review – Part I

Tax Filing Season

Taxpayer Assistance and Service Act Title V: Tax Return Preparers IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel IRS Provides Extensions for Taxpayers Impacted by Hamas Terrorism in Israel

Tax Fraud

Trump and Congress Nullify IRS Reporting Rule for Digital Assets The IRS has started its own Employee Retention Credit Olympics March 22 ERC Voluntary Disclosure Deadline Rapidly Approaching

Tax Reform

Taxpayer Assistance and Service Act Title VII: Whistleblowers Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals The Taxpayer Assistance and Service Act: Title III: Judicial Review

Tax Return Preparers

Taxpayer Assistance and Service Act Title X: Miscellaneous Provisions Taxpayer Assistance and Service Act Title V: Tax Return Preparers IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel

Tax shelters

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales March 22 ERC Voluntary Disclosure Deadline Rapidly Approaching IRS Going All in on Use of ArtificiaI Intelligence

Taxpayer Advocate

Treasury Inspector General for Tax Administration (TIGTA)

Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims Treasury Inspector General Warns Taxpayers of IRS Impersonators As Tax Filing Season Approaches

Trust Fund Recovery Penalty

The Hazards of Trust Fund Recovery Penalties

Trust Fund Taxes

IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel Justice Department Sends Stern Warning to Employers With Continuing Crackdown on Employment Tax Fraud

U.S. Appellate Courts

FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split Tenth Circuit: No Fifth Amendment Defense to the Application of Section 280E IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions

U.S. Court of Federal Claims

Court Ruling Creates Refund Opportunity for Pandemic-Era IRS Interest and Penalties Should You File a Refund Lawsuit if the IRS Won't Process Your ERC Claim?

U.S. Department of Justice (USDOJ)

DOJ Tax Division Leader Departs Amid Large-Scale Reorganization Justice Department Plans to Eliminate Tax Division by End of Summer False Claims Act Fallout from Pandemic Aid: What You Need to Know - A Fox Rothschild Webinar

U.S. Department of the Treasury

IRS and Congress Expand Efforts to Address ERC Fraud Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims U.S. Supreme Court Rules Against Government in FBAR Penalty Case

U.S. District Courts

The IRS has started its own Employee Retention Credit Olympics Should You File a Refund Lawsuit if the IRS Won't Process Your ERC Claim?Conservation Easements: A Year End Review

U.S. Immigration and Customs Enforcement

Employers Beware: ICE Is Ramping Up I-9 Audits to Record Levels

U.S. Securities and Exchange Commission (SEC)

In Wake of New Policy Against “Piling On,” DOJ and SEC Announce Corporate FCPA Resolution SEC: Bitcoin Is Not Governed By Securities Laws Supreme Court Rules That Dodd-Frank’s Whistleblower Protections Cover Only Those Who Report to SEC

U.S. Tax Court

Horse Breeding and Training Expense Deductions? Tax Court Says Neigh The Taxpayer Assistance and Service Act: Title III: Judicial Review Senators Introduce Bipartisan Legislation to Significantly Improve Federal Tax Administration and Procedure

United States Supreme Court

U.S. Supreme Court Rules Against Government in FBAR Penalty Case IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions

USA Patriot Act

FinCEN Launches “FinCEN Exchange” to Enhance Information Sharing With Financial Institutions

USDOJ Swiss Bank Program

Despite Closure of OVDP, Offshore Tax Evasion Crackdown Marches On On Eve of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action to Mitigate Potential for Criminal Prosecution DOJ Offshore Bank Resolution Offers Cooperation Road Map

USDOJ Tax Division

DOJ Tax Division Leader Departs Amid Large-Scale Reorganization Justice Department Plans to Eliminate Tax Division by End of Summer DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

Voluntary disclosure

Self-Disclosure Calculus Remains Complex Under Trump DOJ March 22 ERC Voluntary Disclosure Deadline Rapidly Approaching IRS and Congress Expand Efforts to Address ERC Fraud

Whistleblowers

Taxpayer Assistance and Service Act Title VII: Whistleblowers IRS Launches Online Tool to Simplify Reporting of Tax Fraud and Scams Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

White collar crime

Fox Rothschild's Fourth Annual White Collar Symposium New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program